Note: The degree of the larceny is
determined by the value of the property stolen. See § 53a-122 (first degree); § 53a-123 (second degree); § 53a-124 (third
degree); § 53a-125 (fourth degree); § 53a-125a
(fifth degree); § 53a-125b (sixth degree). The dollar amounts for the
degrees of larceny were increased as of October 1, 2009. See the table in
Introduction to Larceny for the values in effect
prior to that date.

The defendant is charged [in count __]
with larceny by library theft in the (first / second / third / fourth / fifth /
sixth) degree. Larceny simply means theft or stealing. The statute defining
this offense reads in pertinent part as follows:

a person is guilty of library theft
when (he/she) <insert appropriate subsection:>

§ 53a-119 (12)
(A): conceals on (his/her) person or among (his/her) belongings a book or
other archival library materials, belonging to, or deposited in, a library
facility with the intention of removing the same from the library facility
without authority.

§ 53a-119 (12)
(A): without authority removes a book or other archival library materials
from a library facility.

§ 53a-119 (12)
(B): mutilates a book or other archival library materials belonging to, or
deposited in, a library facility, so as to render it unusable or reduce its
value.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Concealed, removed,
mutilated library materialsThe first element is that the
defendant (concealed with intent to remove / removed / mutilated) a book or
other archival library materials.

The statute defines the term "book or
other archival library materials" to include any book, plate, picture,
photograph, engraving, painting, drawing, map, manuscript, document, letter,
public record, microform, sound recording, audiovisual material in any format,
magnetic or other tape, electronic data-processing record, artifact or other
documentary, written or printed material regardless of physical form or
characteristics, or any part thereof, belonging to, on loan to, or otherwise in
the custody of a library facility.

"Library facility" means any public
library, any library of an educational institution, organization or society, any
museum, any repository of public records and any archives.

<Insert appropriate definition:>

To "conceal" means
to hide, and it would include any actions that would render it more difficult to
discover or identify the book.

To "mutilate" is to
render a book imperfect by any physical act short of the total destruction of
the book. Such mutilation must render the book unusable or reduce its value.

Element 2 - Larcenous IntentThe second element is that at the time
the defendant (took / obtained / withheld) the property, (he/she) intended to <insert
as appropriate:>

permanently deprive
the owner of the public record.

permanently
appropriate the public record to (himself/herself) or a third person.

<See
Larceny, Instruction 9.1-1, for a full explanation of this element.>

Element 3 - Value1The third element is that the property
had a value that <insert as appropriate:>

<See
Larceny, Instruction 9.1-1, for a full explanation of this element.>

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant (concealed with intent to remove
/ removed / mutilated) a book or other archival material from a library
facility, 2) (he/she) did so intending to permanently deprive the library of its
property, and 3) the value of the material was <insert value according to
degree charged>.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
larceny by library theft, then you shall find the defendant guilty. On the
other hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.
_______________________________________________________

1
If the defendant is charged with mutilating an item, the appropriate value would
be the reduction in value as a result of the mutilation.